COI Committee, Management, Process, & Review

COI Committee

The COI Committee is a standing committee selected by the Institutional Official (IO) acting on behalf of the Chancellor. The committee is composed of at least five University tenured or tenure-track faculty members, at least one individual from the Office of Business and Finance or Procurement Services, one individual outside of the University community, other individuals appointed at the discretion of the IO, as well as ex officio, non-voting members designated from the below:

The COI Committee meets on an as-needed basis depending on the existence of any newly proposed management plans or existing plans up for renewal. This translates to COI Committee meetings occurring approximately once per month during the year.

The dates and times of the upcoming COI Committee meetings are listed below. Meetings are scheduled for the Spring, Summer, and Fall months based on COI Committee member schedules.

COI Review & Management Process

The first step in the COI review and management process is submission and routing of your COI/COC Disclosure. The form can be filed at any time online through NuRamp, however, it is expected that you will complete the disclosure within 60 days of hire and/or prior to engaging in research, and thereafter annually. After you submit the form, it is routed to your supervisor(s), such as the department chair/director and the Dean’s Office of your College for review and acknowledgement. It then routes to Conflict of Interest staff for review and, in some cases, to the applicable Vice Chancellor-level reviewer for review of outside activities. These individuals review outside activities and any financial disclosures to determine if there is an actual, potential, or perceived COI. Often, completing your disclosure submission is sufficient, requiring no further action. In situations where potential or actual conflicts of interest must be managed beyond disclosure, COI staff, from the Research Compliance Services (RCS) Office, will work with you to present your conflict to the Conflict of Interest Committee (COI Committee) to develop a management plan. The review and approval of outside activities that require management beyond disclosure are completed by the Vice Chancellor-level reviewer.

Financial disclosures should be made by employees at least annually. New financial interests or remuneration should be disclosed throughout the year and within 30 days of being acquired.

Management of actual, potential, or perceived conflicts of interest is completed by the COI Committee. The purpose of the COI Committee is to review and, if necessary, approve plans to manage any identified conflicts of interest. Please note, that some situations may create conflicts that are so significant, they are deemed to be unmanageable. These circumstances are rare but could occur and the conflicted individual or situation may need to be reduced or eliminated.

Examples of Conflicts That May Require Management

Serving in a senior leadership position at a company, while also participating on a committee at UNL that allocates the kinds of resources the outside company provides.

For example, if you have a senior editorial position with a commercial journal and are also on a UNL library committee that recommends journal subscriptions.

Serving as a consultant for a company while performing research at UNL on the company’s technology.

For example, say you are consulting for an outside company. As a result of this consulting relationship, the company wishes to sponsor research at your UNL lab. This may require management if you have received remuneration from the company that triggers certain thresholds. For example, if you have received $5,000 or more in consulting fees from the company in the prior twelve (12) months.

Having an equity or ownership interest in a company (including stock or stock options), while performing research at UNL sponsored by the company.

For example, having an ownership interest in a company that wishes to provide a subaward/subcontract to your lab at UNL. This situation may require management. Management could include identifying an alternative PI, informing students involved with the project of your ownership interest in the company, notification to your Department Chair, and/or even oversight by your Department Chair or the identification of another UNL employee with subject-matter expertise, that can provide un-conflicted oversight.

Please also note that UNL does not allow employees to act as the PI on a project for both the company and UNL.

Performing federally funded research that could affect the financial interests of a company in which you have a personal financial interest (e.g., ownership, equity, remuneration, etc…).

For example, having an ownership interest in a company that commercializes a vaccine you developed while you simultaneously conduct a federally funded study validating that vaccine. This situation may require management given the possible overlapping interests of your company and those of UNL.

Involving students, post-docs, and/or trainees in activities that could directly affect a company in which you, as their supervisor, have a financial interest.

For example, having students/post-docs/trainees work on a project meant to verify the efficacy of an invention being commercialized by your company may require management. Management could include informing those affected students/post-docs/trainees of your interest in the company and recusing yourself from the future academic evaluations and/or grading of those affected individuals (at least in some capacity).

Receiving licensing payments for technology while performing research on that technology.

For example, if you developed technology that you are licensing to an outside entity while also working on a privately or federally sponsored project focused on further testing or development of that technology may require management.

Recommending the use of outside materials to students, post-docs, trainees, in which you have an equity or ownership interest in the supplier of the outside materials.

For example, let’s say you are a faculty member in the Department of Economics and teach various courses on economic principles. You also co-own a tutoring company that provides tutoring services for economic students. You then begin offering tutoring services from your company during lectures and office hours.

Other Resources

Management Plan Template

Management Plan Process Flowchart